FastFacts Feature Presentation

1. FastFactsFeature Presentation June 18, 2010 • We are using audio during this session, so please dial in to our conference line… • Phone number: 877-468-2134 • Participant code: 182500 © 2010 The Johns Hopkins University. All rights reserved.

2. Today’s Topic We’ll be taking a look at… Sub-Recipient Monitoring, Reporting & Records Retention

3. Today’s Presenter Sunanda HolmesAssistant Director - Office of International Business Operations ComplianceController's Office

4. Session Segments Presentation Sunanda will discuss cost sharing, the criteria used for valuations, setting up an auditable system for tracking and program income. During Sunanda’s presentation, your phone will be muted. Q&A After the presentation, we’ll hold a Q&A session. We’ll open up the phone lines, and you’ll be able to ask questions. Sunanda will answer as many of your questions as time allows.

5. Contact Us If you would like to submit a question during the presentation or if you’re having technical difficulties, you can email us at: fastfacts@jhu.edu You can also send us an instant message! GoogleTalk – HopkinsFastFacts@gmail.com AOL Instant Messenger – HopkinsFastFacts MSN – FastFacts@jhu.edu

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7. Survey Survey At the end of this FastFacts session, we’ll ask you to complete a short survey. Your honest comments will help us to enhance and improve future FastFacts sessions.

8. Sub-Recipient Monitoring, Reporting & Records Retention

9. Agenda Overview: • JHU: Where We Are • Assessing Proposed Sub-Recipients • Monitoring Sub-Recipients • Reporting Requirements • Record Keeping and Retention

10. Where We Are… Importance to JHU: • Over $85 million paid to foreign subrecipients in FY09. • Over $30 million was paid out to foreign subrecipients on USAID funded grants in FY09. • Payments made to subrecipients in 62 countries.

11. Definitions Subaward: • Award of financial assistance in the form of money or property in lieu of money • Includes financial assistance • Legal agreement • Made under an award by a recipient to a subrecipient Subrecipient: • Recipient of a subagreement awarded to a foreign or domestic organization (either non-profit, educational institution, or private industry) • Performance of a portion of the work statement covered by a prime agreement with sponsored funding

12. Determining Subrecipient or Vendor Status • An organization is considered to be a subrecipient when it: • Is delegated programmatic responsibility • In contrast to performing services or providing goods to the prime organization as a vendor • An organization is considered to be a vendor when it: • Serves as a dealer, distributor or merchant that provides goods or services for the organization’s own use • Work product is not expected to be publishable in an academic journal • Provides similar goods or services to many different purchasers and operates in a competitive environment.

13. Risk Factors to Consider • Size of the sub-recipient award • Award size relative to the sub-recipient's sponsored research portfolio or total funding from all sources • Percentage passed through • Award complexity, sensitivity of the work and/or extensiveness of the governing regulations • Prior experience with the sub-recipient • Sub-recipient’s country of operation • Degree of external oversight by auditors or sponsoring agencies • Sophistication of sub-recipient's accounting systems and administrative operations

14. Assessing Capacity & Risk Potential • Determine what reporting & monitoring requirements are necessary • Examine organizational documents • Analyze financial statements • Vet the organization and its governing body members in compliance with US law • Review the organization’s capacity to administer a grant • Consider financial health of the organization, • Confirm the organization is fiscally secure and no unusual findings in audited financial statements

15. Monitoring- Why is it Necessary? • USAID requirement • Budget allocation • Deliverables are met • Success of the project • Costs charged are allowable • Quality assurance

16. Types of Monitoring • Program/performance • Subrecipient performance/technical progress • Program output-are they being carried out as planned • Performance quality desired impact being felt • Financial • Invoices prepared in accordance with A-110 and A-133 • Proper accounting practices being followed • Reconciliation • Compliance • USAID regulations • Local laws • JHU policies and procedures

17. Audit Requirements • ADS 591 Provides Policy Directives and Required Procedures for Planning and Conducting Financial Audits of USAID Contractors, Recipients, & Host Government Entities • Foreign for profit and non-profit organizations that expend $300,000 or more per their fiscal year in USAID awards” i.e. as a recipients or subrecipients of USAID grants or cooperative agreements, or as cost reimbursable subcontractors of USAID grant of cooperative agreements, shall have an annual audit conducted in accordance with the Guidelines for Financial Audits Contracted by Foreign Recipients”. • Foreign for profit and non-profit organizations expending less than $300K per their fiscal year under USAID grants or cooperative agreements, or as cost reimbursable contractors of USAID grant or cooperative agreements, are exempt from the audit requirement but have to make their records available if USAID requests.

18. Techniques for Monitoring • Foreign subrecipient questionnaire • Annual letter from Financial Research Compliance • Onsite review- Regular contact through telephone/emails • Program specific • The nature, timing and scope of monitoring foreign sub-recipients may vary by the assessment of risks, funds provided, nature of work, duration of involvement and other factors • A-133 • Sets forth audit procedures for obtaining consistency & uniformity among Federal agencies for audits • Foreign sub-recipients that are exempt from A-133 are required to make their financial records available for review or audit by Federal agencies or pass-thru entities as requested, under the Terms and Conditions of their Agreement

19. What’s New for Subrecipient Monitoring? • Budgeting • Fees associated with routine oversight/monitoring should be included in the proposal and direct charged • Controller’s Office is working on guidelines for audit costs • Monitoring process • Establishing risk assessments • Reviewing documents provided by foreign subs • Reviews/auditing of subs based on established criteria

20. JHU Subrecipient Monitoring Policy JHU policy on subrecipient monitoring • https://www.controller.jhu.edu/policyapp/displayGuidePDF.do?guideId=SUB Questions? • Please contact Rick Inglis in Financial Research Compliance compliance@jhu.edu

21. Reporting Requirements • All financial reporting should be coordinated through Sponsored Projects Shared Services (SPSS). • Expenses reported must balance to SAP. • SF 269’s generally due quarterly, no later than 30 days after the reporting period • Final financial reports due no later than 90 days after end of grant period • Reporting of foreign taxes (VAT) due annually by April 16 • For financial reporting questions, please contact Steve Culp in SPSS sculp@jhu.edu

22. Record Keeping and Retention • Financial records (electronic and paper), supporting documents, statistical records, and all other records pertinent to a sponsored award (or tax return) shall be retained for a period of seven years from the date of submission of all deliverables. • Financial reports, patent reports, technical reports and equipment reports are examples of deliverables. • Field office staff should coordinate retention efforts with the Baltimore office. • For additional guidance from JHU, please refer to: • http://www.controller.jhu.edu/acct_recon/acct_reconciliation_guide/Chapter_2_Reconciliation_Guidelines.pdf

23. In Conclusion Applicable regulations: • 22 CFR 226.26 – Non Federal Audits (A-133 requirements) • Institutions of higher education or other non-profits are subject to the Single Audit Act • 22 CFR 226.52 – Financial Reporting • Designates which forms must be used by USAID recipients • 22 CFR 226.53 – Retention & Access Requirements for Records • Exclusive list of record retention & access Requirements • USAID cannot impose additional retention requirements upon subs • 22 CFR 226.70 – After the Award Requirements (Closeout) • Refer to Subpart D • 226.71 through 226.71 sets forth the closeout procedures and subsequent disallowances for adjustments

24. We’re going to open the phone lines now! There will be a slight pause, and then a recorded voice will provide instructions on how to ask questions over this conference call line. We’ll be answering questions in the order that we receive them. We’ll also be answering the questions that were emailed to us during the presentation. If there’s a question that we can’t answer, we’ll do some research after this session, and then email the answer to all participants. Q&A

25. Thank You! Thank you for participating! We would love to hear from you. Are there certain topics that you would like us to cover in future FastFacts sessions? Would you like to be a FastFacts presenter? Please email us at: fastfacts@jhu.edu

26. Survey Before we close, please take the time to complete a short survey. Your feedback will help us as we plan future FastFacts sessions. Click this link to access the survey… http://connect.johnshopkins.edu/fastfactssurvey/ Thanks again!